People v. Brown

Defendant was found guilty of one count of being an armed habitual criminal and sentenced to 20 years in prison. Defendant appealed, arguing that the trial court abused its discretion by failing to order supplemental discovery and by failing to strike a witness’ testimony. Defendant also argued that the trial court imposed an improper double sentencing enhancement. The appellate court affirmed, finding that defendant forfeited his claims relating to additional discovery because he failed to seek a continuance of the trial, forfeited his claims regarding allegedly improper testimony because he did not object when it was offered at trial, and that defendant’s prior UUWF convictions, which were predicate offenses for the AHC conviction, could be considered during sentencing in the context of defendant’s criminal history and were not an improper enhancement. (HARRIS and LANNERD, concurring)